PRIVACY & COOKIES POLICY

Effective date: 10 September 2026
Version: 1.0

1. Who we are

Unipuler Ltd operates the Unipuler marketplace and connected platform.

For personal data processed for Unipuler's own platform purposes, Unipuler Ltd is generally the relevant controller.

A Seller, Process Partner, Merchant of Record, employer or other participating Business may separately act as an independent controller for personal information it processes for its own purposes.

2. Information we collect

Depending on how you use Unipuler, we may process:

Identity information — name, date of birth and account identity.

Contact information — email, telephone number and address.

Business information — business name, registration details, Business Locations, roles and organisational information.

Account information — login, permissions, settings and account history.

Marketplace information — listings, orders, enquiries, purchases, sales, returns and reviews.

Transaction information — amounts, currency, transaction references, purchasing-balance movements and payment-status information.

Partner information — PP, Finance Partner, Agent and supplier relationships.

Verification information — information required for account, business, transaction, fraud or regulatory checks.

Communications — support messages, emails, marketplace communications and related records.

Technical information — IP address, browser/device data, session/security logs and cookie information.

Marketing preferences — communication and consent preferences.

Other Unipuler modules may collect additional information where necessary for services such as recruitment, HR or workforce management.

3. Why we use information

We may use personal data to:

create and maintain accounts;
provide marketplace services;
process and administer orders;
route transactions;
communicate with users;
provide customer support;
prevent fraud and protect security;
verify Businesses and Partners;
manage returns and disputes;
maintain financial and commercial records;
comply with legal obligations;
improve platform functionality;
send marketing where permitted.

4. Lawful bases

Depending on the purpose, we may rely on:

performance of a contract;
compliance with a legal obligation;
legitimate interests;
consent.

Where special-category or other specially protected data is processed, an additional lawful condition will be used where required.

UK GDPR requires organisations to explain purposes, lawful bases, recipients, retention, rights and international transfers in their privacy information.

5. Legitimate interests

Where we rely on legitimate interests, these may include operating and improving Unipuler, preventing fraud, securing accounts, maintaining commercial records, protecting legal rights and understanding service performance.

We balance those interests against the rights and interests of individuals.

6. Sharing information

We may share relevant information with:

Sellers and Suppliers necessary to fulfil transactions;

Process Partners/Merchants of Record necessary for MoR transactions;

Local Agents and Finance Partners where required for authorised activity;

payment, banking and gateway providers;

delivery and logistics providers;

IT, hosting, communications and security providers;

professional advisers;

regulators, courts, law-enforcement bodies or public authorities where legally required.

We only share information reasonably necessary for the relevant purpose.

7. Seller and MoR data

For a Direct Seller order, information necessary to fulfil the order may be supplied to the Original Seller.

For a Through Unipuler Partner transaction, information may be supplied to the local MoR and relevant supply-chain participants where necessary to perform the transaction.

8. International transfers

Because Unipuler may support international marketplace transactions, personal data may need to be processed outside the United Kingdom.

Where UK data-protection law requires safeguards for an international transfer, we will use an applicable lawful transfer mechanism.

9. Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including contractual, accounting, tax, fraud-prevention, dispute, regulatory and legal requirements.

Different types of records may therefore have different retention periods.

10. Security

Unipuler uses reasonable technical and organisational controls intended to protect personal data against unauthorised access, alteration, disclosure or loss.

No online service can guarantee absolute security.

Users are responsible for keeping credentials secure.

11. Your rights

Depending on applicable law and the circumstances, individuals may have rights including:

access;
rectification;
erasure;
restriction;
data portability;
objection;
withdrawal of consent.

Certain rights are subject to legal limitations.

12. Right to object

Where processing is based on legitimate interests, you may have a right to object.

You may also object to direct marketing at any time.

13. Marketing

We may send marketing communications where permitted by law.

You can use the unsubscribe method provided or update applicable preferences.

Service and transactional communications may still be sent where necessary to operate your account.

14. Cookies

Unipuler uses cookies and similar technologies.

Cookies may include:

Strictly necessary cookies needed for login, security, shopping baskets, checkout and essential functionality.

Preference cookies used to remember choices such as language or interface preferences.

Analytics cookies used to understand usage and improve the platform.

Marketing cookies used for advertising or measurement where applicable.

15. Cookie consent

Non-essential cookies will be used only where the applicable law permits and any required consent has been obtained.

Strictly necessary cookies generally do not require consent where they are essential to provide a service requested by the user, although users should still be informed about them.

16. Managing cookies

Users may manage available cookie preferences through Unipuler's cookie controls and browser settings.

Blocking essential cookies may prevent parts of the service from functioning correctly.

17. Automated processing

Unipuler may use automated rules to assist with fraud detection, security, routing, recommendations or operational workflows.

Where solely automated processing produces legal or similarly significant effects and applicable law requires additional rights or information, Unipuler will provide the required safeguards.

18. Third-party websites

Unipuler may contain links to independent websites.

Their privacy practices are governed by their own policies.

19. Children

Services intended only for adults or business users should not be used by children unless the relevant service expressly permits it and all applicable requirements are satisfied.

20. Complaints

Privacy questions can be submitted through Unipuler Help & Support or Contact Unipuler.

Individuals in the UK also have the right to complain to the Information Commissioner's Office where applicable. The ICO specifically recommends that UK-facing privacy notices explain this right.

21. Updates

We may update this Privacy & Cookies Policy where our services, legal obligations or data-processing practices change.

 

The latest effective date will appear at the top of the Policy.